RCRA REVISION CHECKLIST 28

Standards for Hazardous Waste Storage and Treatment Tank Systems
51 FR 25422-25486
July 14, 1986
as amended on August 15, 1986 at 51 FR 29430-29431
(Non-HSWA Cluster III and HSWA Cluster I)

Note:  1) This checklist is part of both non-HSWA Cluster III and HSWA Cluster I.  States are encouraged to apply for this checklist under non-HSWA Cluster III as its due date occurs sooner than that for the HSWA Cluster.  Those changes which implement HSWA are marked as Footnote 1.  Please read this footnote for further guidance regarding these provisions.  2) Additional interpretation, clarification, and correction of typographical errors relative to this Revision Checklist 28 are subsequently addressed by Revision Checklist 52 (September 2, 1988, 53 FR 34079).  States are encouraged to consider the changes associated with Revision Checklist 52 when implementing the changes addressed by Revision Checklist 28.
	STATE ANALOG IS:
		     ANALOGOUS	  EQUIV-	   MORE	BROADER
   FEDERAL REQUIREMENT     | 	FEDERAL RCRA CITATION    |	   STATE CITATION	| ALENT  |	STRINGENT |	IN SCOPE	

PART 260 - HAZARDOUS WASTE MANAGEMENT SYSTEM:  GENERAL

SUBPART B - DEFINITIONS

DEFINITIONS	 

    1	"aboveground tank"	260.10	

    1	"ancillary equipment"	260.10	

    1	"component"	260.10	

    1	"corrosion expert"	260.10	
    1	"existing tank system" 
or "existing 
component"	260.10	

    1	"inground tank"	260.10	
    1	"installation
inspector"	260.10	
    1	"leak detection
system"	260.10	

    1	"new tank system"	260.10	

    1	"on ground tank"	260.10	

    1	"sump"	260.10	

    1	"tank system"	260.10	

    1	"underground tank"	260.10	
    1	"unfit-for-use tank
system"	260.10	
    1	"zone of engineering
control"	260.10	

PART 261 - IDENTIFICATION AND LISTING OF HAZARDOUS WASTE

SUBPART A - GENERAL

    †	EXCLUSIONS	 
secondary materials 
reclaimed or returned
to process	261.4(a)(8)	

PART 262 - STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE

SUBPART C - PRE-TRANSPORT REQUIREMENTS

ACCUMULATION TIME	 
    1	accumulation
on-site	262.34(a)(1)	
compliance with
Subpart I of 265	262.34(d)(2)	
compliance with
Subpart J of 265	262.34(d)(3)	

PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE
TREATMENT, STORAGE AND DISPOSAL FACILITIES

SUBPART B - GENERAL FACILITY STANDARDS

GENERAL INSPECTION REQUIREMENTS	 
frequency of
inspection	264.15(b)(4)	

SUBPART E - MANIFEST SYSTEM, RECORDKEEPING, AND REPORTING
	 
OPERATING RECORD	 

data requirements	264.73(b)(6)	

SUBPART G - CLOSURE AND POST-CLOSURE

APPLICABILITY	 
    1	closure and post-
closure compliance
with 264.197	264.110(b)(3)	

SUBPART H - FINANCIAL REQUIREMENTS

APPLICABILITY	 
    1	financial
responsibility
compliance
with 264.197	264.140(b)(3)	

SUBPART J - TANK SYSTEMS

APPLICABILITY	 
    1	applicability, tank
systems used for
storing or treating
hazardous waste	264.190	
  1,2	exemptions from
    †	secondary contain-
ment requirements	264.190(a)&(b)	

ASSESSMENT OF EXISTING TANK SYSTEM'S INTEGRITY	 
    1	written assessment
requirement	264.191(a)	
    1	minimum assessment
considerations	264.191(b)	
    1	12 mos. deadline if
materials become
hazardous waste
after 7/14/86	264.191(c)	
    1	tank systems found to
be leaking or unfit for
use	264.191(d)	

DESIGN AND INSTALLATION OF NEW TANK SYSTEMS OR COMPONENTS	 
    1	information to be
included in written
assessments for new
tanks	264.192(a)	
  1,2	new tank installation
procedures; inspection
requirements	264.192(b)	
    1	backfilling require-
ments for new under-
ground tank systems	264.192(c)	

    1	tightness requirement	264.192(d)	
    1	protection of
ancillary equipment	264.192(e)	
    1	corrosion protection
requirements	264.192(f)	
    1	written statements and
certification
statements	264.192(g)	

CONTAINMENT AND DETECTION OF RELEASES	 
  1,2	schedule for providing
secondary containment
for tank systems	264.193(a)	
    1	minimum requirements
for secondary
systems	264.193(b)	
    1	minimum spec.
of secondary
containment	264.193(c)	
    1	devices that satisfy 
the secondary contain-
ment requirements	264.193(d)	
  1,2	additional requirements
for liner and vault
systems, and double-
walled tanks	264.193(e)	
    1	ancillary equipment 
must be provided with
full secondary
containment	264.193(f)	
  1,2	exceptions at
264.193(f)	264.193(f)(1)-(4)	

  †,1	variance requirements	264.193(g)	
    1	requirements for
addressing releases 
from tank systems that
have obtained
variances	264.193(g)(3)&(4)	
    1	procedures for
    †	requesting a variance	264.193(h)	
  1,2	requirements for all
tank systems until 
such time as second-
ary containment is
provided	264.193(i)	

GENERAL OPERATING REQUIREMENTS	 
    1	hazardous waste or 
treatment reagents not 
to be placed in tank
systems	264.194(a)	
    1	minimum controls and
practices to prevent
spills and overflows	264.194(b)	
    1	requirements if a leak
or spill occurs in the
tank system	264.194(c)	

INSPECTIONS	 
    1	schedules & procedure
for inspecting overfill
controls	264.195(a)	
    1	daily inspection
requirements	264.195(b)	
    1	minimum inspection
frequency for cathodic
protection systems	264.195(c)	
    1	documentation in
operating record	264.195(d)	

RESPONSE TO LEAKS OR SPILLS AND DISPOSITION OF LEAKING OR UNFIT-FOR-USE
TANK SYSTEMS	 
    1	immediate removal 
(from service) of
leaking or unfit-for-use
tank systems	264.196	
    1	prevent flows of
additional wastes	264.196(a)	
    1	removal of waste from
tank system or
secondary contain
ment system	264.196(b)	
    1	containment of visible
releases to the
environment	264.196(c)	

  1,2	notifications/reports	264.196(d)	
    1	provision of second-
ary containment,
repair, or closure	264.196(e)	
  1,2	certification closure
requirements	264.196(f)	 

CLOSURE AND POST-CLOSURE CARE	 
    1	general closure
requirements	264.197(a)	
    1	specific requirements 
when contaminated 
soils cannot 
practicably be 
removed or decontam-
inated; closure as a
landfill	264.197(b)	
  1,2	closure plans and 
financial responsibility
requirements for tank
systems without
secondary containment
that fall under 
§264.193(b)-(f) and
are not exempt from
secondary contain-
ments requirements	264.197(c)	

SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES	 
    1	limited placement of I
or R wastes in tank
systems	264.198(a)	
    1	compliance with
maintenance of
protective distances	264.198(b)	

SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES	

    1	limited placement of
incompatible wastes in
tank systems	264.199(a)	
    1	use of tank system 
that previously held
incompatible wastes	264.199(b)	

remove paragraph	264.200	

PART 265 - INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES

SUBPART B - GENERAL FACILITY STANDARDS

GENERAL WASTE ANALYSIS	 
methods for additional
waste analysis	265.13(b)(6)	

GENERAL INSPECTION REQUIREMENTS	 

inspection frequency	265.15(b)(4)	

SUBPART E - MANIFEST SYSTEM, RECORDKEEPING, AND REPORTING

OPERATING RECORD	 
records & results of
analysis & trial tests	265.73(b)(3)	
monitoring, testing, of
analytical data	265.73(b)(6)	

SUBPART G - CLOSURE AND POST-CLOSURE

APPLICABILITY	 
    1	tank systems which 
must comply with land-
fill requirements	265.110(b)(2)	

SUBPART H - FINANCIAL REQUIREMENTS
	 
    1	financial responsi-
bility requirements	265.140(b)	

SUBPART J - TANK SYSTEMS

APPLICABILITY	 
    1	tank systems used for
storing & treating
hazardous waste	265.190	
    1	exemptions from 
    †	secondary containment
requirements	265.190(a)&(b)	

ASSESSMENT OF EXISTING TANK SYSTEMS OR COMPONENTS	 
    1	written assessment
requirement	265.191(a)	
    1	minimum assessment
considerations	265.191(b)	
    1	12 mos. deadline for
materials which 
became hazardous
waste after 7/14/86	265.191(c)	
    1	tank systems found to
be leaking or unfit for
use	265.191(d)	

DESIGN AND INSTALLATION OF NEW TANK SYSTEMS OR COMPONENTS	 
  1,2	information to be 
included in the written
assessment for new
underground tank	265.192(a)	
    1	new tank installation
procedures; inspection
requirements	265.192(b)	
    1	backfilling require-
ments for new under-
ground tank systems	265.192(c)	

    1	tightness requirements	265.192(d)	
    1	protection of
ancillary equipment	265.192(e)	
    1	corrosion protection
requirements	265.192(f)	
    1	written statements and
certification
statements	265.192(g)	

CONTAINMENT AND DETECTION OF RELEASES	 
  1,2	applicability of
secondary containment
requirements	265.193(a)	
    1	minimum requirements 
for secondary contain-
ment systems	265.193(b)	
    1	minimum specifications
of secondary
containment	265.193(c)	
    1	devices that secondary
containment for tanks
must include	265.193(d)	
  1,2	additional requirements
for liner and vault 
systems, and doubled
walled tanks	265.193(e)	
    1	ancillary equipment 
must be provided with
full secondary 
containment	265.193(f)	
    1
    †	exception to 265.193(f)	265.193(f)(1)-(4)	
  1,2
    †	variance requirements	265.193(g)	
    1	procedures for request-
    †	ing a variance	265.193(h)	
  1,2	requirements for all
tanks systems until 
such time as 
secondary containment
is provided	265.193(i)	

GENERAL OPERATING REQUIREMENTS	 
    1	hazardous waste or 
treatment reagents not
to be placed in tank
system	265.194(a)	 
    1	minimum controls and
practices to prevent
spills and overflows	265.194(b)	
    1	requirements if a leak
or spill occurs in the
tank system	265.194(c)	

INSPECTIONS	 

    1	daily inspection
requirements	265.195(a)	
    1	minimum inspection
frequency for cathodic
protection system	265.195(b)	
    1	documentation in
operating record	265.195(c)	

RESPONSE TO LEAKS OR SPILLS AND DISPOSITION OF LEAKING OR UNFIT-FOR-USE
TANK SYSTEMS	 
    1	immediate removal 
(from service) of
leaking or unfit-for-use
tank systems	265.196	
    1	prevent flow of
additional wastes	265.196(a)	
    1	removal of waste from
tank system or
secondary containment
system	265.196(b)	
    1	containment of visible
releases to the
environment	265.196(c)	

    1	notifications/reports	265.196(d)	
    1	provision of secondary
containment, repair, or
closure	265.196(e)	
    1	certification of
major repairs	265.196(f)	

CLOSURE AND POST-CLOSURE CARE	 
    1	general closure
requirements	265.197(a)	
    1	specific requirements
when contaminated 
soils cannot 
practicably be 
removed or decontam-
inated; closure as a 
landfill	265.197(b)	
    1	requirements for tank
systems without
secondary containment
that fall under
§265.193(b)-(f) and 
are not exempt from
secondary containment
requirements	265.197(c)	

SPECIAL REQUIREMENTS FOR IGNITABLE OR REACTIVE WASTES	 
    1	limited placement of I
or R wastes in tank
systems	265.198(a)	
    1	compliance with
maintenance of
protective distance	265.198(b)	

SPECIAL REQUIREMENTS FOR INCOMPATIBLE WASTES	 
    1	limited placement of
incompatible wastes in
tank systems	265.199(a)	
    1	use of tank system 
that previously held
incompatible wastes	265.199(b)	

WASTE ANALYSIS AND TRIAL TESTS	 
    1	waste analysis and
treatment or storage
tests	265.200(a)	
    1	obtain written, docu-
mented information on
similar waste/
operating conditions	265.200(b)	

SPECIAL REQUIREMENTS FOR GENERATORS OF BETWEEN 100 AND 1000 KG/MO THAT
ACCUMULATE HAZARDOUS WASTE IN TANKS	 
general applicability
requirements	265.201(a)	
general operating
requirements for
generators of between
100 and 1000 kg/mo 
of hazardous waste	265.201(b)	
inspection
requirements	265.201(c)	

closure requirements	265.201(d)	
special requirements 
for I or R wastes	265.201(e)	
special requirements
for incompatible
wastes	265.201(f)	

PART 270 - EPA ADMINISTERED PERMIT PROGRAMS:  THE
HAZARDOUS WASTE PERMIT PROGRAM 

SUBPART B - PERMIT APPLICATION

CONTENTS OF PART B:  GENERAL REQUIREMENTS	 
    1	general inspection
schedule	270.14(b)(5)	
    1	copies of closure and
post-closure plans	270.14(b)(13)	

SPECIFIC PART B INFORMATION REQUIREMENTS FOR TANK SYSTEMS	 
  1,2	written certified
assessment of each
tank system	270.16(a)	
    1	dimensions and 
capacity of each tank	270.16(b)	
    1	description of feed
systems, safety cutoff
bypass systems, and
pressure controls	270.16(c)	
    1	diagram of piping,
instrumentation, and
process flow for each
tank system	270.16(d)	
  1,2	description of external
corrosion protection	270.16(e)	
    1	description of new 
tank installation	270.16(f)	
    1	plans and description 
of secondary contain-
ment systems	270.16(g)	
    1	information require-
ments for systems for 
which a variance will
be sought	270.16(h)	
    1	description of controls
and practices to 
prevent spills and 
overflows	270.16(i)	
    1	description of design
and operating for tank
systems handling
ignitible, reactive,
or incompatible wastes	270.16(j)	

SUBPART G - INTERIM STATUS

CHANGES DURING INTERIM STATUS	 
    1	changes made solely 
to comply with 
§265.193 not included
under this section	270.72(e)